NHTSA Interpretation File Search Overview Search Tool Request an Interpretation

NHTSA Interpretation File Search

Overview

NHTSA's Chief Counsel interprets the statutes that the agency administers and the standards and regulations that it issues. Members of the public may submit requests for interpretation, and the Chief Counsel will respond with a letter of interpretation. These interpretation letters look at the particular facts presented in the question and explain the agency’s opinion on how the law applies given those facts. These letters of interpretation are guidance documents. They do not have the force and effect of law and are not meant to bind the public in any way. They are intended only to provide information to the public regarding existing requirements under the law or agency policies.

Understanding NHTSA’s Online Interpretation Files

NHTSA makes its letters of interpretation available to the public on this webpage.

An interpretation letter represents the opinion of the Chief Counsel based on the facts of individual cases at the time the letter was written. While these letters may be helpful in determining how the agency might answer a question that another person has if that question is similar to a previously considered question, do not assume that a prior interpretation will necessarily apply to your situation.

Your facts may be sufficiently different from those presented in prior interpretations, such that the agency's answer to you might be different from the answer in the prior interpretation letter;
Your situation may be completely new to the agency and not addressed in an existing interpretation letter;
The agency's safety standards or regulations may have changed since the prior interpretation letter was written so that the agency's prior interpretation no longer applies; or
Some combination of the above, or other, factors.

Searching NHTSA’s Online Interpretation Files

Before beginning a search, it’s important to understand how this online search works. Below we provide some examples of searches you can run. In some cases, the search results may include words similar to what you searched because it utilizes a fuzzy search algorithm.

Single word search

Example: car
Result: Any document containing that word.

Multiple word search

Example: car seat requirements
Result: Any document containing any of these words.

Connector word search

Example: car AND seat AND requirements
Result: Any document containing all of these words.

Note: Search operators such as AND or OR must be in all capital letters.

Phrase in double quotes

Example: "headlamp function"
Result: Any document with that phrase.

Conjunctive search

Example: functionally AND minima
Result: Any document with both of those words.

Wildcard

Example: headl*
Result: Any document with a word beginning with those letters (e.g., headlamp, headlight, headlamps).

Example: no*compl*
Result: Any document beginning with the letters “no” followed by the letters “compl” (e.g., noncompliance, non-complying).

Not

Example: headlamp NOT crash
Result: Any document containing the word “headlamp” and not the word “crash.”

Complex searches

You can combine search operators to write more targeted searches.

Note: The database does not currently support phrase searches with wildcards (e.g., “make* inoperative”).

Example: Headl* AND (supplement* OR auxiliary OR impair*)
Result: Any document containing words that are variants of “headlamp” (headlamp, headlights, etc.) and also containing a variant of “supplement” (supplement, supplemental, etc.) or “impair” (impair, impairment, etc.) or the word “auxiliary.”

Search Tool

NHTSA's Interpretation Files Search

Displaying 2931 - 2940 of 16517

Interpretations	Date

ID: aiam3441 Open Brian T. Williams, Esq., Assistant Counsel, Saunders Leasing System, Inc., 201 Office Park Drive, Birmingham, AL 35233; Brian T. Williams Esq. Assistant Counsel Saunders Leasing System Inc. 201 Office Park Drive Birmingham AL 35233; Dear Mr. Williams: This responds to your recent request for an interpretation of ou requirements concerning the presence of a 'DOT' symbol on retreaded truck tires. Specifically, you asked whether a retreader would be in violation of any regulations if the retreader purchases casings (use tires to be retreaded) from which the 'DOT' symbol has already been removed, and whether the retreader itself has a duty to remove the 'DOT' symbol.; The retreader is not liable for using casings from which the 'DOT symbol has been removed, although any manufacturer, distributor, dealer, or motor vehicle repair business other than a retreader which removes that symbol from the casings is violating Federal regulations. The retreader does have an affirmative duty to remove the 'DOT' symbol from the sidewall of retreaded truck tires.; The 'DOT' symbol is required to appear on new truck tires as certification that those tires fully comply with all the requirements of Safety Standard No. 119 (49 CFR S571.119), pursuant to the requirement of section S6.5(a) of that standard. Any manufacturer, distributor, dealer, or motor vehicle repair business who removes this symbol would be removing an element of design installed on the tire in compliance with an applicable Federal motor vehicle safety standard. Such removal is expressly prohibited by section 108(a)(2)(A) of the National Traffic and Motor Vehicle Safety Act of 1966, as amended (15 U.S.C. 1397(a)(2)(A)). However, there is no prohibition against subsequent use of these tires for further manufacturing operations, such as retreading. Hence, a retreader using these casings would not subject itself to any liability for violating section 108(a)(2)(A) or any other regulation.; The retreader has an affirmative duty to remove the DOT symbol from th tire during the course of the retreading operation. Part 574, Tire Identification and Recordkeeping (copy enclosed) sets forth the basic tire marking requirements for retreaders of truck tires. Section 574.5 imposes two basic duties on truck tire retreaders - (1) the retreader is required to mold or brand a tire identification number into the sidewall of each tire it retreads, except those retreaded solely for the retreader's own use, and (2) the 'DOT' symbol shall not appear on tires to which no Federal motor vehicle safety standard is applicable. Since there is no safety standard applicable to retreaded truck tires, it follows that no 'DOT' symbol may appear on the sidewall of those tires.; Should you have any further questions or need further information o this matter, feel free to contact me again.; Sincerely, Frank Berndt, Chief Counsel
ID: aiam4384 Open Mr. Jeffrey A. Crawford, Q.A. Manager, Lyn-Mont Manufacturing Co., P. O. Box 11745, 4208 Clubview Drive, Fort Wayne, Indiana 46860; Mr. Jeffrey A. Crawford Q.A. Manager Lyn-Mont Manufacturing Co. P. O. Box 11745 4208 Clubview Drive Fort Wayne Indiana 46860; Dear Mr. Crawford: This responds to your letter concerning Safety Standard No.. 106 Brake Hoses. You asked whether certain proposed labeling for brake hose assemblies would meet the labeling requirements of sections S7.2.3 and S7.2.3.1. As discussed below, the answer to your question is no.; By way of background information, this agency does not provid approvals of motor vehicles or motor vehicle equipment. Under the National Traffic and Motor Vehicle Safety Act, it is the responsibility of the manufacturer to assure that its products comply with applicable safety standards. The following opinion is based on the facts provided in your letter.; Sections S7.2.3 and S7.2.3.1 provide two options for the labeling o air brake hose assemblies made with end fittings that are attached by crimping or swaging. Section S7.2.3 states that such assemblies, except those assembled and installed by a vehicle manufacturer in vehicles manufactured by him, shall be labeled by means of a band around the brake hose assembly as specified in that paragraph, or, at the option of the manufacturer, by means of labeling as specified in section S7.2.3.1.; If the first option is chosen, using a band as specified in sectio S7.2.3, the band must include (a) the symbol DOT, and (b) the manufacturer designation. If the second option, specified in section S7.2.3.1, is chosen, the manufacturer designation must be placed on at least one end fitting of the assembly. (These sections also specify other requirements concerning labeling, such as size of letters, which are not relevant to this interpretation.); Your proposed labeling, placing the manufacturer designation on th band and the symbol DOT on the end fitting, would not meet the requirements of either of these options. If the first option is chosen, the symbol DOT must be placed on the band along with the manufacturer designation. If the second option is chosen, the manufacturer designation must be placed on the end fitting.; Sincerely, Frank Berndt, Chief Counsel
ID: aiam1186 Open Mr. Barry Kulik, 114 West 30 Street, New York, NY 10001; Mr. Barry Kulik 114 West 30 Street New York NY 10001; Dear Mr. Kulik: This is in reply to your letter of May 18, 1973, concerning the metho of testing the sensitivity of seat sensors under sections S7.3 and S7.4 of Federal Motor Vehicle Safety Standard No. 208.; The relevant characteristics of the 'person' referred to in thes sections are found in the weight and dimension table of Section S7.1.3 of the standard. Our testing laboratory will, in all likelihood, be using test dummies purchased from the various commercial dummy manufacturers, whose weights and dimensions conform to S7.1.3 of the standard. Human volunteers could be used, but the dimensional controls are difficult to maintain and we do not regard liver (sic) persons as a practical means of testing sensors under the standard.; Yours truly, Richard B. Dyson, Assistant Chief Counsel
ID: aiam2600 Open Mr. Richard P. Seib, President, United Brake & Clutch, 2100 thru 2116 South Ervay Street, Dallas, TX 75215; Mr. Richard P. Seib President United Brake & Clutch 2100 thru 2116 South Ervay Street Dallas TX 75215; Dear Mr. Seib: This responds to United Brake and Clutch's June 1, 1977, request fo confirmation that use of a brake chamber equipped with separate diaphrams (sic) for application of service brake air pressure and isolated air pressure, along with a mechanical device that automatically holds the brakes in the applied position once they have been applied by means of the protected source of air, would comply with Standard No. 121, Air Brake Systems. The relevant provision of the standard states:; >>>S5.6.3 Application and holding. The parking brakes shall b applied by an energy source that is not affected by loss of air pressure or brake fluid pressure in the service brake system. Once applied, the parking brakes shall be held in the applied position solely by mechanical means.<<<; The National Highway Traffic Safety Administration is unable t 'approve' system designs for compliance with a standard in advance, because there is no way to establish that a vehicle so equipped actually meets the requirements until it has been manufactured.; From your description, it appears that the design would not violate an provision of the parking brake requirement. Our understanding is that the protected source of air pressure is connected separately to the brake chamber, that it is designed to operate even with failure of the service brake chamber diaphram (sic), and that the mechanical holding device operates automatically whenever air pressure in the trailer supply line is at atmospheric pressure. We assume also, that the braking force developed by the protected source of air pressure and maintained by the mechanical device would comply with the requirements of S5.6.1 or S5.6.2 of the standard.; Sincerely, Joseph J. Levin, Jr., Chief Counsel
ID: aiam3912 Open Mr. Jim Preisler, Senior Vice President, Drag Specialties, P.O. Box 9336, Minneapolis, MN 55440; Mr. Jim Preisler Senior Vice President Drag Specialties P.O. Box 9336 Minneapolis MN 55440; Dear Mr. Preisler: This responds to your letter of January 17, 1985, concerning Standar No. 205, Glazing Materials. Your company manufactures an aftermarket replacement motorcycle windscreen, which incorporates auxiliary wind deflectors. Standard No. 205 specifies that the upper portion of the windshield can be made out of item 1, 6, 10, or 11 glazing materials. The glazing used in the auxiliary wind deflectors can be made out of item 1, 2, 4, 10, or 11A glazing materials. You said that the glazing material used in the windscreen and deflector meets the requirements for both item 4 and 6 glazing materials. You asked whether you can mark both those components as item 4/6 glazing materials. The answer is that you can mark them as item 4/6 materials.; Section S6 of the standard sets out the certification and markin requirements for each item of glazing material. It provides that each piece of glazing material shall be marked, in accordance with section 6 of American National Standard Safety Code for Safety Glazing Materials for Glazing Motor Vehicles Operating on Land Highways' Z-26.1 - 1977, January 26, 1977, as supplemented by Z26.1a, July 3, 1980, with a number signifying that it meets the performance requirement set for that particular glazing item number. In your case, the glazing material meets all of the requirements set for two separate item numbers. Since your product conforms to the requirements for both items 4 and 6 the agency has no objection to marking the components with both item numbers.; Sincerely, Jeffrey R. Miller, Chief Counsel
ID: aiam5595 Open Mr. Robert J. Ponticelli President American International 1040 Avenida Acaso Camarillo, CA 93012; Mr. Robert J. Ponticelli President American International 1040 Avenida Acaso Camarillo CA 93012; "Dear Mr. Ponticelli: This replies to your letter of July 25, 1995 asking for an opinion 'on the use of Electro-Luminescent Strip Lighting on motor vehicles.' The device in question 'is an ornamental light which produces less than .05 candela/sq. inch.' You have enclosed a brochure which shows the strip in use as a license plate frame and to mark the sides or perimeter of a vehicle. We assume that you are not asking about the license plate frame but only the 'Lighted Pin Striping'. The 'Lighted Pin Striping' comes in 'basic white' but once applied, seven colors of overlay tape are available to change the color. The brochure shows it in shades of blue and pink. You would like our views 'on the installation of this product by regulated parties such as new car dealers and non-regulated entities such as aftermarket specialty shops and vehicle owners.' We are pleased to provide you with the interpretation you seek. The basic obligation of a new-car dealer is to deliver a new car that remains in compliance with all the applicable Federal motor vehicle safety standards for which its manufacturer has certified compliance. In other words, the dealer must ensure that none of its actions before the sale of a new vehicle create a noncompliance with a safety standard. Further, if a dealer alters a vehicle before sale other than by the addition, substitution, or removal of readily attachable components, or minor finishing operations such as painting, is required to certify that the altered vehicle continues to meet the standards. The Federal new vehicle standard that relates to your product is Standard No. 108 Lamps, Reflective Devices, and Associated Equipment. This standard permits a new car dealer to add supplementary lighting equipment such as the luminescent strip if the supplementary equipment does not impair the effectiveness of the lighting equipment required by Standard No. 108. The most common cause of impairment is lighting equipment that creates confusion with, or distraction from, the purpose of any item of required lighting equipment. Under Standard No. 108's lighting scheme, the color of lamps on the front of a vehicle are restricted to white and amber. On the side of the vehicle, side marker lamps and reflectors must be only amber to the front and red to the rear. Rear lighting is red or amber, with the color white permitted for the backup lamp only. The Lighted Pin Striping comes in a variety of colors. Your brochure shows one that is pink or red in color mounted on the front of a vehicle. We believe it possible that a motorist seeing a color of light on the front of the vehicle generally used on the rear or on the side at the rear could be distracted from the driving task. There is also the possibility that the strip would be bright enough to mask and thereby reduce the effectiveness of an adjacent front or rear turn signal, or stop lamp. In general, the agency tries to discourage the use of novelty lighting devices because of the uncertain reaction an unfamiliar light or reflection may cause in other drivers on the roadway. However, the determination as to whether installation of the lighting strip would impair the efficiency of required lighting equipment is initially that of the new car dealer who must determine whether his modifications to a new vehicle might take it out of compliance. Unless that determination is clearly erroneous, NHTSA will not contest it. With respect to sales in the aftermarket, installation by a manufacturer, distributor, dealer, or motor vehicle repair business of the lighting strip would be prohibited if the use of the strip would, in the words of the statute, 'make inoperative' any of the required lighting equipment. We tend to equate 'make inoperative' and 'impair effectiveness' so that the same considerations would have to be taken into account in installing the lighting equipment on a used as well as a new car. However, this prohibition does not extend to the vehicle owner who, under Federal law, may install the lighting strip regardless of its effect upon compliance. Nevertheless, even if novelty lighting equipment does not violate Federal law, the ultimate decision of its acceptability is that of the State in which the lighting strip is to be used. It is our understanding that, for example, that California requires any emitted or reflected light from the front of vehicles to be white or yellow in color, which would appear to preclude installation of the lighting strip in colors other than these. For an opinion on the treatment of the lighting strip under State laws, we suggest that you write for an opinion to the American Association of Motor Vehicle Administrators, 4600 Wilson Boulevard, Arlington, Va. 22203. If you have any further questions, you may refer them to Taylor Vinson of this Office (202-366-5263). Sincerely, John Womack Acting Chief Counsel";
ID: aiam2250 Open Mr. Ron Stacy, School District No. 12, Adams County, 10280 North Huron Street, Denver, CO 80221; Mr. Ron Stacy School District No. 12 Adams County 10280 North Huron Street Denver CO 80221; Dear Mr. Stacy: This responds to your March 5, 1976, request for written permission t deactivate the '121 brake system' of a school bus manufactured from a Ford chassis with a Kelsey-Hayes antilock system.; From the description of the problems you have encounted (sic) with thi vehicle, I assume that you do not intend to disconnect the entire '121 brake system', but only one or more antilock systems installed in satisfaction of the 'no lockup' requirements of S5.3.1 of Standard No. 121, Air Brake Systems. The National Highway Traffic Safety Administration (NHTSA) has made a finding that early models of the antilock system supplied on transit and intercity buses is characterized by malfunction that warrants its deactivation until a correction is fully developed. This finding was not made with regard to the Kelsey-Hayes system that equips your vehicle.; Section 108(a)(2)(A) of the National Traffic and Motor Vehicle Safet Act (15 U.S.C. S 1397(a)(2)(a)) prohibits, with one exception, knowing disconnection of the antilock system by manufacturers, distributors, dealers, or repair businesses. A person that does not fall into these categories is not prohibited from disconnection of the system. Other State or Federal requirements, such as those of the Bureau of Motor Carrier Safety, may prohibit disconnection. In any case, the NHTSA urges that you not disconnect safety devices without consulting the vehicle manufacturer with regard to the safest configuration of the vehicle.; Sincerely, Frank A. Berndt, Acting Chief Counsel
ID: aiam0797 Open Mr. Satoshi Nishibori, Engineering Representative, Nissan Motor Company, Ltd., 560 Sylvan Avenue, Englewood Cliffs, NJ 07632; Mr. Satoshi Nishibori Engineering Representative Nissan Motor Company Ltd. 560 Sylvan Avenue Englewood Cliffs NJ 07632; Dear Mr. Nishibori: This is in reply to your letters of July 25 and 28, 1972, on th subject of the positioning of seat backs for the purposes of testing under Standards No. 208 and 210.; The 'nominal design riding position' specified in Standard 208 an formerly employed in Standard 210 is the position considered by the manufacturer as that most likely to be used by vehicle occupants. In our compliance tests, we ask the manufacturer of each vehicle to be tested to advise us of the correct position.; The term 'most upright position' used in Standard 210 was adopted i part to avoid the need to go to the manufacturers for advice each time we tested a vehicle's seats. Under S4.3.2 of the standard, the seat back is adjusted to the position which places the seating surface most nearly in a vertical position.; There have, however, been difficulties with the use of the 'mos upright position', in cases where that position is not the same as the position used by the manufacturer to establish the seating reference point. Because S4.3.2 also calls for the positioning of the SAE J826 mannikin on the seating reference point, there is a possibility that the mannikin cannot be correctly positioned. This does not appear to be a serious discrepancy, but it is one that should be resolved, and we intend to do so by appropriate amendment in the Federal Register.; Sincerely, Richard B. Dyson, Assistant Chief Counsel
ID: aiam1885 Open Honorable Herman E. Talmadge, United States Senate, Washington, DC 20510; Honorable Herman E. Talmadge United States Senate Washington DC 20510; Dear Senator Talmadge: This is in response to your letter requesting information concernin correspondence from Mr. James A. Graham, commenting on a proposed amendment to the Federal bumper standard.; On January 2, 1975, the National Highway Traffic Safety Administratio (NHTSA) issued a Federal Register notice (copy enclosed) proposing to reduce the current 5-mph bumper impact requirements to 2.5 mph until the 1979 model year. The impact requirements would have been increased to 4 mph for 1979 and later model year cars.; The proposal was based primarily on the results of two agency-sponsore studies which indicated that the cost and weight of many current production bumpers, in light of inflation and fuel shortages, made the bumpers no longer cost beneficial. Information presented at public hearings on the bumper notice and comments submitted to the docket in response to the proposal have brought to light additional data. The NHTSA has carefully examined all of this evidence and reviewed its studies in light of the new information. As a result, the agency has concluded that the 5 mph protection level should not be reduced. This decision is contained in a Federal Register notice that was published on March 12, 1975 (Docket No. 74-11, Notice 7, Docket No. 73-19, Notice 6).; In his letter Mr. Graham objects to the standard's regulation o surface damage, such as dents, stating that this is not the type of damage which should be addressed by an agency developing safety standards. The surface damage criteria are proposed as part of a standard being promulgated under Title I of the Motor Vehicle Information and Cost Savings Act (Pub. L. 92-513). The Cost Savings Act directs the National Highway Traffic Safety Administration to develop a bumper standard that will obtain the maximum feasible reduction of costs to the public and the consumer. As such, the standard is not to be limited to affecting safety-related damage. Factors such as insurance costs and consumer time and inconvenience are to be considered in the rulemaking as well.; Mr. Graham's comments will be placed in the public docket where the will receive every consideration.; We appreciate your interest and that of Mr. Graham in this area o motor vehicle safety and performance.; Sincerely, Robert L. Carter, Associate Administrator, Motor Vehicl Programs;
ID: aiam0282 Open Mr. William J. Henrick, Assistant Counsel, The General Tire & Rubber Company, One General Street, Akron, OH 44309; Mr. William J. Henrick Assistant Counsel The General Tire & Rubber Company One General Street Akron OH 44309; Dear Mr. Henrick: This is in response to your letter of May 17, 1971, concerning th applicability of the Tire Identification and Record Keeping Regulation (49 C.F.R. 574) to trailers as expressed in our letter of March 18, 1971, to Mr. Charles O. Verrill.; As you mentioned in your letter, under the regulation, a vehicle deale has the responsibilities of a tire dealer if he adds or changes the tires on a vehicle he sells. This was considered appropriate because the manufacturer has little, if any, control over which tires go on which vehicles if the tires are shipped separately. In such a case, the vehicle dealer will be mounting the tires and therefore it is logical that he record the name and address of the first purchaser along with the identification number of the tires mounted on the vehicle and forward this information to the tire manufacturer.; The Tire Identification and Record Keeping Regulation and th Certification Regulation for Vehicles Manufactured in Two or More Stages are two completely different regulatory matters. The factors which dictate the related responsibilities of the incomplete vehicle manufacturer and the final-stage manufacturer for purposes of certification are not necessarily relevant to the tire identification regulations.; Sincerely, Lawrence R. Schneider, Acting Chief Counsel

Request an Interpretation

You may email your request to Interpretations.NHTSA@dot.gov or send your request in hard copy to:

The Chief Counsel
National Highway Traffic Safety Administration, W41-326
U.S. Department of Transportation
1200 New Jersey Avenue SE
Washington, DC 20590

If you want to talk to someone at NHTSA about what a request for interpretation should include, call the Office of the Chief Counsel at 202-366-2992.

Please note that NHTSA’s response will be made available in this online database, and that the incoming interpretation request may also be made publicly available.

Interpretations	Date

ID: aiam3441 Open Brian T. Williams, Esq., Assistant Counsel, Saunders Leasing System, Inc., 201 Office Park Drive, Birmingham, AL 35233; Brian T. Williams Esq. Assistant Counsel Saunders Leasing System Inc. 201 Office Park Drive Birmingham AL 35233; Dear Mr. Williams: This responds to your recent request for an interpretation of ou requirements concerning the presence of a 'DOT' symbol on retreaded truck tires. Specifically, you asked whether a retreader would be in violation of any regulations if the retreader purchases casings (use tires to be retreaded) from which the 'DOT' symbol has already been removed, and whether the retreader itself has a duty to remove the 'DOT' symbol.; The retreader is not liable for using casings from which the 'DOT symbol has been removed, although any manufacturer, distributor, dealer, or motor vehicle repair business other than a retreader which removes that symbol from the casings is violating Federal regulations. The retreader does have an affirmative duty to remove the 'DOT' symbol from the sidewall of retreaded truck tires.; The 'DOT' symbol is required to appear on new truck tires as certification that those tires fully comply with all the requirements of Safety Standard No. 119 (49 CFR S571.119), pursuant to the requirement of section S6.5(a) of that standard. Any manufacturer, distributor, dealer, or motor vehicle repair business who removes this symbol would be removing an element of design installed on the tire in compliance with an applicable Federal motor vehicle safety standard. Such removal is expressly prohibited by section 108(a)(2)(A) of the National Traffic and Motor Vehicle Safety Act of 1966, as amended (15 U.S.C. 1397(a)(2)(A)). However, there is no prohibition against subsequent use of these tires for further manufacturing operations, such as retreading. Hence, a retreader using these casings would not subject itself to any liability for violating section 108(a)(2)(A) or any other regulation.; The retreader has an affirmative duty to remove the DOT symbol from th tire during the course of the retreading operation. Part 574, Tire Identification and Recordkeeping (copy enclosed) sets forth the basic tire marking requirements for retreaders of truck tires. Section 574.5 imposes two basic duties on truck tire retreaders - (1) the retreader is required to mold or brand a tire identification number into the sidewall of each tire it retreads, except those retreaded solely for the retreader's own use, and (2) the 'DOT' symbol shall not appear on tires to which no Federal motor vehicle safety standard is applicable. Since there is no safety standard applicable to retreaded truck tires, it follows that no 'DOT' symbol may appear on the sidewall of those tires.; Should you have any further questions or need further information o this matter, feel free to contact me again.; Sincerely, Frank Berndt, Chief Counsel
ID: aiam4384 Open Mr. Jeffrey A. Crawford, Q.A. Manager, Lyn-Mont Manufacturing Co., P. O. Box 11745, 4208 Clubview Drive, Fort Wayne, Indiana 46860; Mr. Jeffrey A. Crawford Q.A. Manager Lyn-Mont Manufacturing Co. P. O. Box 11745 4208 Clubview Drive Fort Wayne Indiana 46860; Dear Mr. Crawford: This responds to your letter concerning Safety Standard No.. 106 Brake Hoses. You asked whether certain proposed labeling for brake hose assemblies would meet the labeling requirements of sections S7.2.3 and S7.2.3.1. As discussed below, the answer to your question is no.; By way of background information, this agency does not provid approvals of motor vehicles or motor vehicle equipment. Under the National Traffic and Motor Vehicle Safety Act, it is the responsibility of the manufacturer to assure that its products comply with applicable safety standards. The following opinion is based on the facts provided in your letter.; Sections S7.2.3 and S7.2.3.1 provide two options for the labeling o air brake hose assemblies made with end fittings that are attached by crimping or swaging. Section S7.2.3 states that such assemblies, except those assembled and installed by a vehicle manufacturer in vehicles manufactured by him, shall be labeled by means of a band around the brake hose assembly as specified in that paragraph, or, at the option of the manufacturer, by means of labeling as specified in section S7.2.3.1.; If the first option is chosen, using a band as specified in sectio S7.2.3, the band must include (a) the symbol DOT, and (b) the manufacturer designation. If the second option, specified in section S7.2.3.1, is chosen, the manufacturer designation must be placed on at least one end fitting of the assembly. (These sections also specify other requirements concerning labeling, such as size of letters, which are not relevant to this interpretation.); Your proposed labeling, placing the manufacturer designation on th band and the symbol DOT on the end fitting, would not meet the requirements of either of these options. If the first option is chosen, the symbol DOT must be placed on the band along with the manufacturer designation. If the second option is chosen, the manufacturer designation must be placed on the end fitting.; Sincerely, Frank Berndt, Chief Counsel
ID: aiam1186 Open Mr. Barry Kulik, 114 West 30 Street, New York, NY 10001; Mr. Barry Kulik 114 West 30 Street New York NY 10001; Dear Mr. Kulik: This is in reply to your letter of May 18, 1973, concerning the metho of testing the sensitivity of seat sensors under sections S7.3 and S7.4 of Federal Motor Vehicle Safety Standard No. 208.; The relevant characteristics of the 'person' referred to in thes sections are found in the weight and dimension table of Section S7.1.3 of the standard. Our testing laboratory will, in all likelihood, be using test dummies purchased from the various commercial dummy manufacturers, whose weights and dimensions conform to S7.1.3 of the standard. Human volunteers could be used, but the dimensional controls are difficult to maintain and we do not regard liver (sic) persons as a practical means of testing sensors under the standard.; Yours truly, Richard B. Dyson, Assistant Chief Counsel
ID: aiam2600 Open Mr. Richard P. Seib, President, United Brake & Clutch, 2100 thru 2116 South Ervay Street, Dallas, TX 75215; Mr. Richard P. Seib President United Brake & Clutch 2100 thru 2116 South Ervay Street Dallas TX 75215; Dear Mr. Seib: This responds to United Brake and Clutch's June 1, 1977, request fo confirmation that use of a brake chamber equipped with separate diaphrams (sic) for application of service brake air pressure and isolated air pressure, along with a mechanical device that automatically holds the brakes in the applied position once they have been applied by means of the protected source of air, would comply with Standard No. 121, Air Brake Systems. The relevant provision of the standard states:; >>>S5.6.3 Application and holding. The parking brakes shall b applied by an energy source that is not affected by loss of air pressure or brake fluid pressure in the service brake system. Once applied, the parking brakes shall be held in the applied position solely by mechanical means.<<<; The National Highway Traffic Safety Administration is unable t 'approve' system designs for compliance with a standard in advance, because there is no way to establish that a vehicle so equipped actually meets the requirements until it has been manufactured.; From your description, it appears that the design would not violate an provision of the parking brake requirement. Our understanding is that the protected source of air pressure is connected separately to the brake chamber, that it is designed to operate even with failure of the service brake chamber diaphram (sic), and that the mechanical holding device operates automatically whenever air pressure in the trailer supply line is at atmospheric pressure. We assume also, that the braking force developed by the protected source of air pressure and maintained by the mechanical device would comply with the requirements of S5.6.1 or S5.6.2 of the standard.; Sincerely, Joseph J. Levin, Jr., Chief Counsel
ID: aiam3912 Open Mr. Jim Preisler, Senior Vice President, Drag Specialties, P.O. Box 9336, Minneapolis, MN 55440; Mr. Jim Preisler Senior Vice President Drag Specialties P.O. Box 9336 Minneapolis MN 55440; Dear Mr. Preisler: This responds to your letter of January 17, 1985, concerning Standar No. 205, Glazing Materials. Your company manufactures an aftermarket replacement motorcycle windscreen, which incorporates auxiliary wind deflectors. Standard No. 205 specifies that the upper portion of the windshield can be made out of item 1, 6, 10, or 11 glazing materials. The glazing used in the auxiliary wind deflectors can be made out of item 1, 2, 4, 10, or 11A glazing materials. You said that the glazing material used in the windscreen and deflector meets the requirements for both item 4 and 6 glazing materials. You asked whether you can mark both those components as item 4/6 glazing materials. The answer is that you can mark them as item 4/6 materials.; Section S6 of the standard sets out the certification and markin requirements for each item of glazing material. It provides that each piece of glazing material shall be marked, in accordance with section 6 of American National Standard Safety Code for Safety Glazing Materials for Glazing Motor Vehicles Operating on Land Highways' Z-26.1 - 1977, January 26, 1977, as supplemented by Z26.1a, July 3, 1980, with a number signifying that it meets the performance requirement set for that particular glazing item number. In your case, the glazing material meets all of the requirements set for two separate item numbers. Since your product conforms to the requirements for both items 4 and 6 the agency has no objection to marking the components with both item numbers.; Sincerely, Jeffrey R. Miller, Chief Counsel
ID: aiam5595 Open Mr. Robert J. Ponticelli President American International 1040 Avenida Acaso Camarillo, CA 93012; Mr. Robert J. Ponticelli President American International 1040 Avenida Acaso Camarillo CA 93012; "Dear Mr. Ponticelli: This replies to your letter of July 25, 1995 asking for an opinion 'on the use of Electro-Luminescent Strip Lighting on motor vehicles.' The device in question 'is an ornamental light which produces less than .05 candela/sq. inch.' You have enclosed a brochure which shows the strip in use as a license plate frame and to mark the sides or perimeter of a vehicle. We assume that you are not asking about the license plate frame but only the 'Lighted Pin Striping'. The 'Lighted Pin Striping' comes in 'basic white' but once applied, seven colors of overlay tape are available to change the color. The brochure shows it in shades of blue and pink. You would like our views 'on the installation of this product by regulated parties such as new car dealers and non-regulated entities such as aftermarket specialty shops and vehicle owners.' We are pleased to provide you with the interpretation you seek. The basic obligation of a new-car dealer is to deliver a new car that remains in compliance with all the applicable Federal motor vehicle safety standards for which its manufacturer has certified compliance. In other words, the dealer must ensure that none of its actions before the sale of a new vehicle create a noncompliance with a safety standard. Further, if a dealer alters a vehicle before sale other than by the addition, substitution, or removal of readily attachable components, or minor finishing operations such as painting, is required to certify that the altered vehicle continues to meet the standards. The Federal new vehicle standard that relates to your product is Standard No. 108 Lamps, Reflective Devices, and Associated Equipment. This standard permits a new car dealer to add supplementary lighting equipment such as the luminescent strip if the supplementary equipment does not impair the effectiveness of the lighting equipment required by Standard No. 108. The most common cause of impairment is lighting equipment that creates confusion with, or distraction from, the purpose of any item of required lighting equipment. Under Standard No. 108's lighting scheme, the color of lamps on the front of a vehicle are restricted to white and amber. On the side of the vehicle, side marker lamps and reflectors must be only amber to the front and red to the rear. Rear lighting is red or amber, with the color white permitted for the backup lamp only. The Lighted Pin Striping comes in a variety of colors. Your brochure shows one that is pink or red in color mounted on the front of a vehicle. We believe it possible that a motorist seeing a color of light on the front of the vehicle generally used on the rear or on the side at the rear could be distracted from the driving task. There is also the possibility that the strip would be bright enough to mask and thereby reduce the effectiveness of an adjacent front or rear turn signal, or stop lamp. In general, the agency tries to discourage the use of novelty lighting devices because of the uncertain reaction an unfamiliar light or reflection may cause in other drivers on the roadway. However, the determination as to whether installation of the lighting strip would impair the efficiency of required lighting equipment is initially that of the new car dealer who must determine whether his modifications to a new vehicle might take it out of compliance. Unless that determination is clearly erroneous, NHTSA will not contest it. With respect to sales in the aftermarket, installation by a manufacturer, distributor, dealer, or motor vehicle repair business of the lighting strip would be prohibited if the use of the strip would, in the words of the statute, 'make inoperative' any of the required lighting equipment. We tend to equate 'make inoperative' and 'impair effectiveness' so that the same considerations would have to be taken into account in installing the lighting equipment on a used as well as a new car. However, this prohibition does not extend to the vehicle owner who, under Federal law, may install the lighting strip regardless of its effect upon compliance. Nevertheless, even if novelty lighting equipment does not violate Federal law, the ultimate decision of its acceptability is that of the State in which the lighting strip is to be used. It is our understanding that, for example, that California requires any emitted or reflected light from the front of vehicles to be white or yellow in color, which would appear to preclude installation of the lighting strip in colors other than these. For an opinion on the treatment of the lighting strip under State laws, we suggest that you write for an opinion to the American Association of Motor Vehicle Administrators, 4600 Wilson Boulevard, Arlington, Va. 22203. If you have any further questions, you may refer them to Taylor Vinson of this Office (202-366-5263). Sincerely, John Womack Acting Chief Counsel";
ID: aiam2250 Open Mr. Ron Stacy, School District No. 12, Adams County, 10280 North Huron Street, Denver, CO 80221; Mr. Ron Stacy School District No. 12 Adams County 10280 North Huron Street Denver CO 80221; Dear Mr. Stacy: This responds to your March 5, 1976, request for written permission t deactivate the '121 brake system' of a school bus manufactured from a Ford chassis with a Kelsey-Hayes antilock system.; From the description of the problems you have encounted (sic) with thi vehicle, I assume that you do not intend to disconnect the entire '121 brake system', but only one or more antilock systems installed in satisfaction of the 'no lockup' requirements of S5.3.1 of Standard No. 121, Air Brake Systems. The National Highway Traffic Safety Administration (NHTSA) has made a finding that early models of the antilock system supplied on transit and intercity buses is characterized by malfunction that warrants its deactivation until a correction is fully developed. This finding was not made with regard to the Kelsey-Hayes system that equips your vehicle.; Section 108(a)(2)(A) of the National Traffic and Motor Vehicle Safet Act (15 U.S.C. S 1397(a)(2)(a)) prohibits, with one exception, knowing disconnection of the antilock system by manufacturers, distributors, dealers, or repair businesses. A person that does not fall into these categories is not prohibited from disconnection of the system. Other State or Federal requirements, such as those of the Bureau of Motor Carrier Safety, may prohibit disconnection. In any case, the NHTSA urges that you not disconnect safety devices without consulting the vehicle manufacturer with regard to the safest configuration of the vehicle.; Sincerely, Frank A. Berndt, Acting Chief Counsel
ID: aiam0797 Open Mr. Satoshi Nishibori, Engineering Representative, Nissan Motor Company, Ltd., 560 Sylvan Avenue, Englewood Cliffs, NJ 07632; Mr. Satoshi Nishibori Engineering Representative Nissan Motor Company Ltd. 560 Sylvan Avenue Englewood Cliffs NJ 07632; Dear Mr. Nishibori: This is in reply to your letters of July 25 and 28, 1972, on th subject of the positioning of seat backs for the purposes of testing under Standards No. 208 and 210.; The 'nominal design riding position' specified in Standard 208 an formerly employed in Standard 210 is the position considered by the manufacturer as that most likely to be used by vehicle occupants. In our compliance tests, we ask the manufacturer of each vehicle to be tested to advise us of the correct position.; The term 'most upright position' used in Standard 210 was adopted i part to avoid the need to go to the manufacturers for advice each time we tested a vehicle's seats. Under S4.3.2 of the standard, the seat back is adjusted to the position which places the seating surface most nearly in a vertical position.; There have, however, been difficulties with the use of the 'mos upright position', in cases where that position is not the same as the position used by the manufacturer to establish the seating reference point. Because S4.3.2 also calls for the positioning of the SAE J826 mannikin on the seating reference point, there is a possibility that the mannikin cannot be correctly positioned. This does not appear to be a serious discrepancy, but it is one that should be resolved, and we intend to do so by appropriate amendment in the Federal Register.; Sincerely, Richard B. Dyson, Assistant Chief Counsel
ID: aiam1885 Open Honorable Herman E. Talmadge, United States Senate, Washington, DC 20510; Honorable Herman E. Talmadge United States Senate Washington DC 20510; Dear Senator Talmadge: This is in response to your letter requesting information concernin correspondence from Mr. James A. Graham, commenting on a proposed amendment to the Federal bumper standard.; On January 2, 1975, the National Highway Traffic Safety Administratio (NHTSA) issued a Federal Register notice (copy enclosed) proposing to reduce the current 5-mph bumper impact requirements to 2.5 mph until the 1979 model year. The impact requirements would have been increased to 4 mph for 1979 and later model year cars.; The proposal was based primarily on the results of two agency-sponsore studies which indicated that the cost and weight of many current production bumpers, in light of inflation and fuel shortages, made the bumpers no longer cost beneficial. Information presented at public hearings on the bumper notice and comments submitted to the docket in response to the proposal have brought to light additional data. The NHTSA has carefully examined all of this evidence and reviewed its studies in light of the new information. As a result, the agency has concluded that the 5 mph protection level should not be reduced. This decision is contained in a Federal Register notice that was published on March 12, 1975 (Docket No. 74-11, Notice 7, Docket No. 73-19, Notice 6).; In his letter Mr. Graham objects to the standard's regulation o surface damage, such as dents, stating that this is not the type of damage which should be addressed by an agency developing safety standards. The surface damage criteria are proposed as part of a standard being promulgated under Title I of the Motor Vehicle Information and Cost Savings Act (Pub. L. 92-513). The Cost Savings Act directs the National Highway Traffic Safety Administration to develop a bumper standard that will obtain the maximum feasible reduction of costs to the public and the consumer. As such, the standard is not to be limited to affecting safety-related damage. Factors such as insurance costs and consumer time and inconvenience are to be considered in the rulemaking as well.; Mr. Graham's comments will be placed in the public docket where the will receive every consideration.; We appreciate your interest and that of Mr. Graham in this area o motor vehicle safety and performance.; Sincerely, Robert L. Carter, Associate Administrator, Motor Vehicl Programs;
ID: aiam0282 Open Mr. William J. Henrick, Assistant Counsel, The General Tire & Rubber Company, One General Street, Akron, OH 44309; Mr. William J. Henrick Assistant Counsel The General Tire & Rubber Company One General Street Akron OH 44309; Dear Mr. Henrick: This is in response to your letter of May 17, 1971, concerning th applicability of the Tire Identification and Record Keeping Regulation (49 C.F.R. 574) to trailers as expressed in our letter of March 18, 1971, to Mr. Charles O. Verrill.; As you mentioned in your letter, under the regulation, a vehicle deale has the responsibilities of a tire dealer if he adds or changes the tires on a vehicle he sells. This was considered appropriate because the manufacturer has little, if any, control over which tires go on which vehicles if the tires are shipped separately. In such a case, the vehicle dealer will be mounting the tires and therefore it is logical that he record the name and address of the first purchaser along with the identification number of the tires mounted on the vehicle and forward this information to the tire manufacturer.; The Tire Identification and Record Keeping Regulation and th Certification Regulation for Vehicles Manufactured in Two or More Stages are two completely different regulatory matters. The factors which dictate the related responsibilities of the incomplete vehicle manufacturer and the final-stage manufacturer for purposes of certification are not necessarily relevant to the tire identification regulations.; Sincerely, Lawrence R. Schneider, Acting Chief Counsel

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